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EPA releases new Label Review Manual

The US-EPA has released a new Label Review Manual (LRM) in May 2014. According to the manual, "the goal of the LRM is to improve the quality and consistency of labels" and helping state label reviews, registration and others in producing readable and unambiguous labels.

Additionally, "[p]esticide product labels provide critical information about how to safely handle and legally apply pesticide products. Unlike most other types of product labels, pesticide labels are enforceable, and all of them carry the statement: 'It is a violation of Federal law to use this product in a manner inconsistent with its labeling.'"

As we constantly state in trainings, the "label is the law."

According to the US-EPA website, they consider the document to be an instructional aid that does not establish new guidance, but instead compiles existing interpretations of statutory and regulatory provisions and reiterates existing Agency policies.

The LRM is divided into some interesting and easy-to-read chapters that tend to follow those sections on current labels: General Label Requirements, Ingredient Statement, Use Classification, Precautionary Statement, Environmental Hazards, Worker Protection Labeling, Directions for Use, and Storage and Disposal. There are also chapters on less common topics, such as Labelling claims, Graphics and Symbols, and Physical and Chemical Hazards.

One of the largest chapters is Worker Protection Labeling. While the purpose of the LRM is for labels, this chapter (like many of the others) is a great reference on what is required for worker protection.

The Worker Protection Labeling chapter puts in one place the requirements for minimum clothing, as well as standards for gloves and respirators. Some of this is new language approved by NIOSH (National Institute for Occupational Safety and Health). For example, new labels that follow the new language in the LRM will now conform to current standards for descriptions of respirators and filters to use for each type of pesticide. The same would apply for gloves.

The charts in this section would be GREAT for posting as reference if you use products requiring special respirators or gloves.

So what does this mean for you?

Well, generally most people reading this aren't producing a label for a product, but ultimately you will be reading a label. In the future, hopefully labels are going to be easier to read and follow. You won't be referenced to a product that might have been registered years ago. False and spurious claims won't be allowed. Confusing wordings hopefully will be a thing of the past.

There should be less confusion in the future in the selection of the correct gloves and respirator and filters and when purchasing gloves and respirators. Until now, there has been multiple ways labels have identified the same glove or respirator with some labels retaining outdated designations.

Of course, this won't happen overnight. As long as a product isn't changed, the old label will still apply, and of course, you MUST follow that label.

But as companies create different products and formulations, the new guidelines will apply. Labels will slowly change. And hopefully for the better.